Memorandum Findings of Fact and Opinion
BRUCE, Judge:
Respondent determined deficiencies in petitioner's income taxes of $3,960.04 for 1944, $7,753.75 for 1945, and $3,420.56 for 1946. The petitioner does not contest certain adjustments. The issue for decision is whether the Commissioner properly included in petitioner's income for the taxable years involved the pro rata share of the net earnings of a partnership known as
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